hsctpa Posted December 2, 2020 Share Posted December 2, 2020 This is a two part question regarding these amendments. At first we (our TPA firm) were thinking that the CARES Act amendment would not be required for those plans that did not offer the distributions or loan provisions in the Act. However, because there is a provision in the ACT allowing suspension of RMD's for 2020 and all our documents include RMD language, we are thinking that we should adopt the amendment for all our plans as the most prudent option, even if there are no participants in the Plan in RMD status. Agreed? We are behind in our amendments so have not amended yet for the HBBA 2018. We were just going to wait until after 2021 tax season (early August) to amend for both. Is there any reason why we shouldn't? Link to comment Share on other sites More sharing options...
Lou S. Posted December 2, 2020 Share Posted December 2, 2020 If there are no participants age 70 1/2 I don't see where the amendment is required. You simply follow the terms of the current document and process RMDs for the zero participants that require them. As for timing as long as you are in the remedial amendment period you should be fine. Link to comment Share on other sites More sharing options...
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